2013-04-10_PERMIT FILE - C1981019 (82)

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RULE 2 PERMITS the sagebrush steppe mix to areas between 10% and 15% slope (as further described at length in this revision) after consultation with the Division without modifying Map 46. Colowyo's Annual Reclamation Report provided to the Division will provide specific details of topsoil applied and the seed mix applied to each reclamation block. Interim revegetation monitoring will identify core areas that would benefit from interseeding, etc. to ensure Colowyo's ability to establish and ideally exceed the sagebrush steppe acreage establishment target. Interim revegetation monitoring efforts will also provide the information necessary to identify the areas that will be formally designated as sagebrush steppe and grassland for Phase III Bond Release data collection purposes. Map 46 identifies areas (according to compliance with the proposed PMT surface) that should exhibit slopes between 0% and approximately 10% and are specifically targeted to receive a shallow application of topsoil and the sagebrush steppe seed mix. Such flexibility will in no way be allowed to circumvent the requirement to maintain a proper life -of -mine topsoil balance and further supports the overall plan objective to improve shrub establishment and meet specified targets such as at least 350 acres of sagebrush steppe establishment with at least 175 acres of core sagebrush steppe establishment. This also includes the ability to take credit for up to 175 acres of ecotonal areas from targeted sagebrush steppe seeded areas and grassland targeted areas (evolved) that exhibit high enough shrub establishment success to qualify for Phase III bond release under the sagebrush steppe criteria. Materials such as Map 46 provide the division with Colowyo's general plan for demonstrating likely success with the specific target listed above and is not a commitment by Coloywo to achieve sagebrush steppe Phase III Bond release criteria on every acre initially seeded to sagebrush steppe. Areas receiving initial sagebrush steppe establishment metrics may be released as grassland if they are later designated as such through interim revegetation monitoring. Colowyo will discuss any planned deviations from the reclamation plan with DRMS prior to their implementation to ensure compliance with the overall goals of the reclamation program. Colowyo doesn't anticipate any changes to the reclamation plan that would require formal revision unless PMT changes are requested that would require DRMS evaluation and approval in addition to any appropriate updates to reclamation plan materials. Related to this flexibility and as presented in Section 4.15, Colowyo commits to woody plant density success criteria (among several others) for Phase III bond release that are ecologically defensible and appropriate. This commitment is in the interest of promoting the momentum of the bond release process and the pursuit of a "land -use" based reclamation program. Furthermore, this commitment on the part of Colowyo is based on the fact that recent experience and advancements in reclamation science now dictate less stringent requirements for a 10 -year bond responsibility period. Historically, woody plant density success criterion, developed more than 30 years ago when Colowyo began surface operations, were established at too high a level over too short a time period to be consistently achievable on a large scale given the technology and regulatory limitations at the time. Revegetation Plan Following the retopsoiling of an area, any necessary fertilization, surface preparation, berm development, construction of contour furrows, and seeding of the reclamation will take place. The reclamation seed mixture for areas targeting grassland (and erosion control), as shown in Volume 15, Table 2.05 -7, Reclamation Seed Mixture, contains sufficient diversity for ecological stability and is appropriate for reclamation areas in the Collom area. The seed mixture contains a variety of grasses, fortis and shrub species well adapted to the soil and moisture conditions found at Colowyo. The diverse seed mixture is capable of self - selection for each reclaimed micro - habitat encountered in the reclaimed areas. The diverse seed mixture is required to ensure quick erosion control for the first few years of reclamation as well as obtaining the desired post- mining vegetative community with the same seasonal variety and lifeform of the pre -mined area. Collom — Rule 2, Page 113 Revision Date: 9/28/11 Revision No.: PR -03